Surveillance Audit: Re-Certification Audit: Certification Audit: # Scope extension audit:

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1 Bureau Veritas Certification North America, Inc. SFI Forest Management Audit Report Greenspoint Park Dr., Suite 300 S Houston, TX Phone (281) : Toll Free (800) Company Name CLAW FORESTRY SERVICES, LLC Contact Person William Van Devender Address 3544 Lorna Ridge Drive, Hoover, AL Phone / Fax PQC Code E01E Contract Number US Certification Audit: X Re-Certification Audit: Surveillance Audit: # Scope extension audit: Audit Summary Introduction This report summarizes the results of the initial audit conducted on the Claw Forestry Services, LLC SFI program for forest management. The audit was conducted by Mr. Gary Boyd, Bureau Veritas Certification lead auditor. Mr. Boyd is an SAF certified forester and a Georgia registered forester. Audit Scope, Objectives and Process The scope of this audit is Forest management. The audit was conducted against the SFI Standard Forest Management Edition. All SFI Objectives were covered during the audit. There was no substitution or modification of indicators. Specifically, two objectives of the SFI audit were to verify that the Program Participant s SFI Program is in conformance with the SFI Objectives, Performance Measures, and Indicators, and any additional indicators that the Program Participant chooses, and verify whether the Program Participant has effectively implemented its SFI Standard program requirements on the ground. Standard Bureau Veritas Certification protocols and forms were applied throughout the audit as provided by the most recent version of the Bureau Veritas Certification SFI Auditor Handbook available on the auditor access website. Audit Plan The stage 1 audit was conducted for one day at the Hoover, AL office on November 28, The stage 2 field audit was conducted for one day on December 4, A closing meeting was conducted at the end of the day on the 4th. An audit plan was developed and is on file with Bureau Veritas Certification Company Information Claw Forestry Services, LLC is a full-service forest management firm that offers a comprehensive range of timberland investment and forest management services. The primary ownership for this certificate is Valley Creek Land & Timber, LLC, an ownership entity for approximately 68,000 acres of property in the heart of Alabama. Not Applicable Multi-Site Requirements -1- Bureau Veritas Certification SFI Forest Management Audit Report V.2.1 July 2017

2 Audit Results The stage 1 audit was conducted to determine if Claw Forestry s system documentation met the requirements of the SFI Standard Forest Management Edition. The stage 2 field audit consisted of a review of two harvest sites (one thinning and one clearcut); two regeneration/chemical site prep/tree planting sites and one special site. Objective 1-Forest Management Planning: Claw Forestry Services has a robust GIS inventory system. An acquisition inventory cruise was complete in Plans are being finalized in establishing a periodic inventory cruise schedule. The organization contracts with FRC to update inventory volumes on a quarterly basis. The organization is aware of potential impact of climate change on forest inventory. A general site description provides a land classification system. The agency is harvesting well below the estimated annual allowable harvest rate. The lands within this certificate have been actively mined by its previous ownership U S Steel. Claw Forestry is not converting forest types due to the history if this land base. Objective 2-Forest Health and Productivity: Stands are designated for artificial regeneration on a stand-by-stand basis. Natural stands are maintained with natural regeneration in areas that have steep topography or are streamside management zones. Claw Forestry is monitoring and managing its forest to prevent impacts from pests through thinning and salvage clearcuts. Claw Forestry uses chemical applications as its primary site preparation tool. Two sites that had been chemically site prepared during 2017 were visited during this audit. Herbicides used demonstrated a narrow spectrum of chemicals and were below label rates. The contractor was a licensed applicator. The two sites inspected demonstrated implementation of application BMPs. There was no off target spray observed. The company does not use any WHO Type 1A or 1B pesticides, nor does it use any banned under the Stockholm Convention. Soil productivity was protected on the two harvest sites audited. Use of water bars and debris placed in skid trails were observed at both sites. No rutting or soil compaction was observed during the audit. Objective 3-Protection and Maintenance of Water Resources: Compliance with the Alabama BMPs was evident on both harvest sites reviewed during the audit. Streamside management zones were very well established. Erosion control measures were in place on roads and skid trails. Logging contracts contain a requirement for compliance to BMPs. Objective 4-Conservation of Biological Diversity: Claw Forestry operates a wildlife management and biodiversity program appropriate to the scale of its operations. There are no known occurrences of T&E species. While the company has not received Natural Heritage occurrence data of its land base, foresters were very knowledgeable of the NatureServe Explorer and Alabama Natural Heritage Program websites. They had lists of species that are known to occur in the counties they operate. An opportunity for improvement was issued encouraging the company to acquire specific elemental occurrence data for their land base. Stand-level wildlife elements were observed on the two harvest sites visited during the audit. The company uses irregular stand shapes and maintains the retention of trees and/or snags within the cutover areas. -2- Bureau Veritas Certification SFI Forest Management Audit Report V.2.1 July 2017

3 Claw employees were aware of significant occurrences of non-native invasive species; the two most prevalent being kudzu and Chinese privet. The company has not incorporated research results into their management planning resulting in a minor non-conformance. The minor non-conformance was closed on 12/19/2107. Objective 5-Management of Visual Quality and Recreational Benefits: The majority of the land base is in rural areas even though it is close to the Birmingham AL metropolitan area. Aesthetics are not a primary concern. Average clearcut size for 2017 was 64 acres. The one clearcut observed during the audit complied with greenup requirements. Objective 6-Protection of Special Sites: Claw Forestry has identified a few special sites on its property. All are currently cemeteries and are mapped and protected from harvest activities. One cemetery was visited during this audit. This cemetery was well marked and protected. Objective 7-Efficient Use of Fiber Resources: Harvest operations demonstrated an appropriate level of utilization. Objective 8: Recognize and Respect Indigenous People s Rights: Claw Forestry has a policy in place to respect the rights of indigenous peoples. No know federally recognized tribes exist in the area of this land base, but the agency has a process to respond to public inquiries. Objective 9-Legal and Regulatory Compliance: The company s system to achieve compliance consists of contract language, pre-activity planning processes, training, and monitoring. ClawForestry has a written policy in place to comply with social laws. They have received no communication from interested parties concerning it or its supplier s performance relative to ILO core conventions. Objective 10-Forestry Research, Science and Technology: The company works with a consulting firm that conducts research on tree species selection and tree improvement. Claw Forestry employees have access to information on the potential impacts of climate change on forest health and productivity, and wildlife and wildlife habitat. Objective 11-Training and Education: Claw Forestry has a statement of commitment to the SFI standard that is available to all employees. All employees are now required to receive training specific to their SFI responsibilities. The company requires loggers to have at least one person on each job who maintains current training status. The company s written agreement with loggers contains a requirement for the use of qualified loggers. The logger training program contains all the requirements of Objective 12-Community Involvement and Landowner Outreach: Claw Forestry is in the process of joining the Alabama SIC. The AL SIC has recommended the company start paying dues in A Claw employee started attending SIC meetings in Claw Forestry has sponsored the UGA Workshop on Timberland Investment. Objective 13: Public Land Management Responsibilities: -3- Bureau Veritas Certification SFI Forest Management Audit Report V.2.1 July 2017

4 Not Applicable Objective 14-Communications and Public Reporting: Since this is the company s initial audit, it has not yet provided an audit report to SFI, Inc. or completed an annual progress report. However, it has the GIS and record-keeping capabilities to provide information to complete the report. Objective 15-Management Review: Claw Forestry conducted management review prior to stage 1 on November 1, The company has procedures to describe its management review process and the data needed to present to management. Findings Previous non-conformances: Not applicable; This is the initial certification audit. Non-conformances: One minor non-conformance was issued during the stage 2 audit to Objective 4; Performance Measure 4; Indicator 2 where the company had not addressed a methodology to incorporate research results and field applications of biodiversity and ecosystem research into forest management decisions. The minor non-conformance was closed on 12/19/2107. Opportunities for Improvement: Four Opportunities for Improvement were identified during the certification audit. While the company had developed measures to meet these indicators, improvements can be made to insurance conformance to these indicators in the future. 1. PM 2.3, Ind. 6: Rutting criteria was informally stated. No specific criteria is written into procedures. 2. PM 4.1, Ind. 4: Company had copies of the State Wildlife Action Plan and the State Forest Action Plan, but were uncertain how to incorporate the results of these plans into their management planning. 3. PM 4.4, Ind. 1: Company had access to general data and species databases from NatureServe and the AL Natural Heritage program from the counties in which they manage lands. The company had not acquired data from NatureServe or AL Natural Heritage specific to their managed lands. 4. PM 9.1, Ind. 1: Company had access to federal regulations and were aware of state and local regulations but did not have access to these state and local regulations. Notable Practices: None Logo/label use: Claw Forestry has not yet used the SFI logo, but may do so in the future. The company has procedures in place to contact SFI to obtain approval before doing so. They do not intend to use the BVC logo. SFI reporting: This is Claw Forestry s initial audit, so no audit reports have yet been submitted. Review of Previous Audit Cycle Not Applicable -4- Bureau Veritas Certification SFI Forest Management Audit Report V.2.1 July 2017

5 Conclusions The closing meeting was conducted the afternoon of December 4, One minor nonconformance was issued during stage 2 and has not been closed to date. The company is recommended for certification to the SFIS FM Standard upon closure of this minor nonconformance. The minor non-conformance was closed on 12/19/2107. SEE SF61 FOR AUDIT NOTES Summary of Audit Findings: Audit Date(s): From: November 28, 2017 To: December 4, 2017 Number of SF02 s Raised: Major: 0 Minor: 1 Is a follow up visit required: Yes No X Date(s) of follow up visit: Follow-up visit remarks: Team Leader Recommendation: Corrective Action Plan(s) Accepted Yes X No X N/A Date: 12/18/17 Proceed to/continue Certification Yes X No X N/A Date: 12/19/17 All NCR s Closed Yes X No X N/A Date: 12/19/17 Standard audit conducted against: 1) SFIS FM Edition 3) 2) 4) Team Leader (1): Team Members (2,3,4 ) Gary Boyd 2) 3) 4) 5) Scope of Supply: (scope statement must be verified and appear in the space below) Forest Management Accreditation's ANAB Number of Certificates 1 Proposed Date for Next Audit Event Date November 2018 Audit Report Distribution Claw Forestry Services - William J Van Devender Jr - william@claw-forestry.com BVC: Yvonne Martinez - yvonne.martinez.ext@bureauveritas.com -5- Bureau Veritas Certification SFI Forest Management Audit Report V.2.1 July 2017

6 Clause Opening Meeting Closing Meeting Participants: Discussions: Participants: Discussions: Audit Report Lee Miller, Tim Smith, Gary Boyd Introductions Scope of the audit Audit schedule/plan Nonconformance types Major / Minor Review of previous nonconformances N/A. Process approach to auditing and audit sampling Confidentiality agreement Termination of the audit Appeals process Closing meeting timing Lee Miller, Tim Smith, William Van Devender, Gary Boyd Introductions and appreciation for selecting Bureau Veritas Certification. Review of audit process - process approach and sampling. Review of OFIs and System Strengths Nonconformances 1 Minor Date for next audit. Reporting protocol and timing -6- Bureau Veritas Certification SFI Forest Management Audit Report V.2.1 July 2017

7 SF02/NA NONCONFORMITY REPORT Company Name and Site: Claw Forestry Services, LLC Contract #: Type of audit (e.g., initial, surveillance): Team Leader: US Initial Certification Gary Boyd Date: Standard and Clause #: Team Member: 12/04/ SFI Forest Management / Major Minor Other Documents (if applicable): Company Representative: X Lee Miller SF02#: REQUIREMENT OF AUDITED STANDARD: A methodology to incorporate research results and field applications of biodiversity and ecosystem research into forest management decisions. OBSERVED NONCONFORMITY: Company Policies & Procedures or Forest Management Plan ( ) does not address this indicator. Corrective Action Plan Date: ROOT CAUSE ANALYSIS AND CORRECTIVE ACTION PLAN (To be completed by the Company. Plan to be submitted in 30 days) 12/18/17 Company Representative: Lee Miller Root Cause Analysis and Corrective Action Root Cause: Failed to incorporate methodology of using wildlife habitat and biodiversity conservation research results into forest management decisions. Corrective Action Plan: Investigate effects of our forest management operations on wildlife habitat and biodiversity conservation through state extension publications, journal articles, or continuing education training classes. ROOT CAUSE AND CORRECTIVE ACTION PLAN ACCEPTANCE REPORT (To be completed by Bureau Veritas Certification Verify effective identification of Root Cause and acceptance of Corrective Action Plan) Root Cause: Accepted Corrective Action Plan: Accepted Plan Accepted: Yes X No Comments: Auditor: Gary Boyd Date: 12/18/2017 CORRECTIVE ACTION IMPLEMENTATION To be completed by Company Provide objective evidence. Not to exceed: 90 Days 1 year Corrective Action Completion Date: Company Representative: Lee Miller Corrective Action Implementation: Updated Policy Manual with procedure and method to satisfy performance indicator. Method used to verify effectiveness of action taken: Procedure will be reviewed and modified annually, if necessary, to meet performance indicator. CORRECTIVE ACTION IMPLEMENTATION ACCEPTANCE REPORT (To be completed by Bureau Veritas Certification Acceptance of Corrective Action taken) Accepted: Yes X No Nonconformance Closed: Yes X No Follow Up Comments: Auditor: Gary Boyd Date: 12/19/ Bureau Veritas Certification SFI Forest Management Audit Report V.2.1 July 2017